In a nonprecedential opinion issued March 9, 2026, the Minnesota Court of Appeals affirmed the dismissal of drug charges against two women, ruling that a police officer exceeded his authority by re-entering a vehicle to search for weapons after already seizing a large knife from the floorboard.
The case underscores the constitutional limits of a “protective search” during a traffic stop in Minnesota. While officers have a right to ensure their safety, the court found that this specific search constituted an unlawful expansion of the stop.
The Stop: A Lane Violation Leads to a Knife
The incident began in the early morning hours of January 2025. A Worthington police officer initiated a traffic stop after observing a car commit lane violations. The vehicle pulled into a gas station parking lot.
Upon approaching the passenger side, the officer noted several factors:
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The Vehicle: The passenger provided documentation showing the car was a rental. The officer noted that rental cars are often associated with criminal activity on the route between Sioux Falls and Minneapolis.
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Behavior: The passenger appeared nervous with shaking hands.
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The Weapon: A large, unsheathed kitchen knife was lying on the passenger floorboard near the passenger’s feet.
The Escalation: Securing the Knife
Concerned for his safety, the officer ordered both the passenger and driver out of the vehicle. As the driver exited, the officer reached in and successfully secured the knife.
However, despite having the weapon in his possession, the officer then knelt down and leaned his upper body fully into the passenger compartment. Using a flashlight to search under the seat, he discovered a bag of controlled substances. This led to a full vehicle search and the discovery of additional drugs.
The Legal Question: When Can an Officer Search for Weapons?
Both defendants were charged with drug possession but moved to suppress the evidence, arguing the second search—conducted after the knife was seized—was unconstitutional. The Nobles County District Court agreed and dismissed the complaints.
The State of Minnesota appealed, arguing the officer had “reasonable, articulable suspicion” to believe more weapons were present, citing:
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The late hour.
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The use of a rental car.
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The fact that the officer was alone and outnumbered.
Why the Search Was Unlawful
The Court of Appeals affirmed the lower court’s decision, highlighting three specific reasons why this search crossed the line:
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The Knife Was Already Secured: Unlike previous cases (such as Michigan v. Long), where a weapon remained reachable by a suspect, the officer here had already neutralized the threat by taking the knife.
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The Defendants Were Cooperative: The court noted the women were calm and cooperative. They made no “furtive movements,” did not appear under the influence, and made no attempt to re-enter the car.
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Lack of a Specific Threat: While the court acknowledged the general dangers of late-night stops for lone officers, these general risks do not automatically create a “reasonable suspicion of dangerousness” in every case.
Court Finding: The “totality of the circumstances” did not support a reasonable suspicion that the defendants were dangerous once the initial knife was removed.
The Takeaway
The court concluded that the re-entry into the car was an “unlawful expansion of the scope of the stop.” Because the initial search was unconstitutional, all evidence found as a result was suppressed, and the charges were dismissed.
This ruling serves as a vital reminder that the Fourth Amendment requires officers to tailor their actions strictly to the specific threat at hand. A single, secured weapon—without further indicators of danger—is not a “blank check” for a warrantless vehicle search.
